G.R. No. 10170 ; September 10, 1915
JUANA FAJARDO, plaintiff-appellant, vs. AGUEDA MAGSACAY, defendant-appellee.

FACTS:
Damian Sandin owned a parcel of land in Nueva Ecija. Upon his death, his heirs in Spain authorized Attorney Antonio Constantino to sell the land. On September 26, 1910, Constantino sold it to Eugenia Paguia, who, on the following day, sold it to Paulino Candelaria (son of Agueda Magsacay). Later, on September 6 and November 4, 1912, Paulino Candelaria sold the entire land to Mariano Limjap.

Juana Fajardo filed a complaint against Agueda Magsacay. She alleged that they had formed a partnership to purchase the land from Constantino, contributing P3,400 equally. However, the deed of sale was executed in the name of Paulino Candelaria. In support, Fajardo presented a notarial instrument (Exhibit A) dated June 17, 1912, signed by both parties, acknowledging their equal ownership of the land purchased and stating that the land was being surveyed and divided, with Magsacay binding herself to have a separate instrument made for Fajardo’s share.

Fajardo did not seek recovery of her half of the land but instead claimed indemnity for damages, valuing the land at P90 per hectare and demanding P9,405 as her share of the estimated total value.

The defendant presented a private document (Exhibit 1) dated October 18, 1912, signed by Fajardo, stating that she received P2,260 from Magsacay “in payment of what was owing me… for a parcel of our land which she sold.” Fajardo admitted receiving this amount but claimed it was only an advance, pursuant to an alleged agreement that she would be paid at the rate of P90 per hectare. The trial court found this alleged agreement unproven, disbelieving the sole witness supporting it.

ISSUE:
Whether the amount of P2,260 received by Juana Fajardo from Agueda Magsacay, as evidenced by the signed receipt (Exhibit 1), constituted full payment for her share in the land or merely a partial payment.

RULING:
The Supreme Court AFFIRMED the trial court’s judgment absolving the defendant. The Court held that the document (Exhibit 1) was clear and categorical, stating it was received “in payment of what was owing.” It contained no language indicating it was a partial payment or an installment on a larger sum. The terms of the document extinguished any obligation related to the payment for Fajardo’s share in the sold land. The alleged separate agreement for payment at P90 per hectare was correctly found by the trial court to be unsubstantiated by credible evidence. Therefore, Fajardo’s claim for additional indemnity had no legal basis.